Draft — Pending Review

Privacy Policy

Last updated: [EFFECTIVE DATE]

DRAFT — PENDING LEGAL REVIEW

This Privacy Policy is a business draft and has not yet been approved by legal counsel. It should not be relied upon as the final description of Pro Car Finder's privacy practices until the company completes its data-mapping, service-provider review, and legal review.

Introduction

This Privacy Policy explains how [LEGAL BUSINESS NAME], doing business as Pro Car Finder ("Pro Car Finder," "we," "us," or "our"), collects, uses, discloses, and retains information when people use our websites, applications, browser extension, account-management tools, inventory services, forms, the Facebook Lead Assistant, and related services collectively referred to as the "Services."

This policy applies to information handled by Pro Car Finder in connection with the Services. It does not govern independent websites, platforms, dealerships, service providers, or third parties that maintain their own privacy practices.

Section 1 — Information We Collect

A. Account and Profile Information

We collect information that identifies or relates to an account or profile, which may include:

  • Name
  • Email address
  • Telephone number
  • Job title
  • Account role
  • Dealership or company
  • Pro Car Finder account number
  • Rooftop or dealer-group association
  • Invitation and account-status information
  • Authentication and account-security information

Pro Car Finder does not collect Facebook passwords or dealership website passwords. Where authentication is handled through your own Facebook account or another provider, Pro Car Finder does not store those passwords.

B. Dealership and Inventory Information

To provide the inventory workflow, we may process information about an authorized dealership and its inventory, which may include:

  • Dealership name and location
  • Public website and inventory URLs
  • Authorized inventory-source configuration
  • Connector identifiers and configuration
  • Vehicle VIN
  • Stock number
  • Year, make, model, trim
  • Price and mileage
  • Exterior and interior color
  • Body style and condition
  • Vehicle photos
  • Availability and sold status
  • Salesperson assignments and claims
  • Price-change and inventory-sync activity

Inventory may come from authorized public dealership websites, customer-provided files, supported feeds, or approved integrations. Customers are responsible for having authorization to provide or connect their inventory sources, and for complying with any applicable website terms or legal restrictions.

C. Website and Form Information

We collect information submitted through forms and communications, including:

  • Request a Demo
  • Contact
  • Account onboarding
  • Support requests
  • Dealership invitations
  • Billing inquiries
  • Privacy or data requests
  • Other communications

This information may include:

  • Contact details
  • Company information
  • Product interest
  • Inventory size
  • Rooftop count
  • Number of salespeople
  • Lead volume
  • CRM information
  • Communication-channel interests
  • Message contents
  • Consent confirmations

Do not submit passwords, connector keys, API keys, payment-card information, Social Security numbers, driver's-license information, confidential customer data, or other sensitive information through general website forms.

D. Payment and Subscription Information

Pro Car Finder may collect subscription selection, billing contact information, plan, setup fee, account status, invoices, transaction identifiers, and payment status.

Depending on the payment workflow, payment-card information may be collected and processed directly by an approved payment provider such as Square, rather than directly by Pro Car Finder. The extent to which Pro Car Finder receives or stores payment-card information depends on the payment architecture, which is still being confirmed.

Pro Car Finder does not make a claim of PCI compliance unless and until that status is documented and verified.

E. Technical and Usage Information

The Services may collect technical and usage information, including:

  • IP address
  • Browser and device information
  • Operating system
  • Pages or features used
  • Dates and times of activity
  • Referring URLs
  • Session and authentication events
  • Extension version
  • Inventory sync status
  • Posting-preparation diagnostics
  • Error, performance, and security logs
  • General usage and interaction information

The specific analytics, logging, or diagnostic tools used are still being reviewed and will be described accurately once confirmed.

F. Browser Extension Information

The browser extension may process the information necessary to:

  • Connect authorized inventory
  • Import vehicle details and photos
  • Associate inventory with the correct account or rooftop
  • Prepare vehicle information
  • Assist the signed-in user with Marketplace listing preparation
  • Diagnose posting-preparation errors
  • Report successful or rejected listing attempts when configured

The extension does not collect Facebook passwords. Users remain signed into their own Facebook accounts and remain responsible for reviewing and publishing their own listings. The extension does not access Facebook messages unless a separate authorized feature that requires that access is actually implemented.

G. Facebook Lead Assistant Information

When the Facebook Lead Assistant is enabled, information may include:

  • Customer name and contact information
  • Vehicle interest
  • Customer message content that the salesperson chooses or enters
  • Generated reply suggestions
  • Appointment requests
  • Trade-in or financing interest
  • Communication preferences
  • Consent and opt-out records
  • Assigned dealership, rooftop, department, or employee
  • Approved dealership and inventory information used to support responses
  • Interaction, appointment, sold-outcome, and note records

The Facebook Lead Assistant does not automatically read or send personal Facebook Marketplace messages, and it does not collect Facebook passwords. The salesperson opens the conversation, chooses or enters the customer's message, reviews the suggestions, and manually sends each response. Pro Car Finder is not affiliated with or endorsed by Meta or Facebook.

H. Information From Service Providers and Integrations

Information may be received from approved providers used for:

  • Hosting
  • Authentication
  • Inventory services
  • Form processing
  • Payment processing
  • Communications
  • Scheduling
  • Analytics
  • Security
  • Customer support
  • AI functionality

A provider is not listed publicly unless its use is confirmed, its role is understood, public disclosure is approved, and the wording accurately reflects the provider's processing.

Section 2 — How We Use Information

We use information for purposes including:

  • Providing and operating the Services
  • Creating and administering accounts
  • Connecting authorized inventory
  • Maintaining rooftop separation
  • Preparing vehicle information
  • Monitoring price and availability changes
  • Processing dealership invitations and roles
  • Supporting browser-extension activity
  • Delivering the Facebook Lead Assistant
  • Recording interactions and outcomes
  • Delivering authorized leads to the customer's CRM
  • Providing customer service
  • Processing subscriptions and payments
  • Preventing fraud, abuse, and unauthorized access
  • Diagnosing errors
  • Improving reliability and usability
  • Communicating about accounts and requests
  • Enforcing agreements and acceptable-use rules
  • Complying with legal obligations
  • Protecting users, customers, Pro Car Finder, and others

We do not engage in behavioral advertising unless and until such activity actually occurs.

Section 3 — AI Processing and Human Oversight

The Facebook Lead Assistant may use automated systems to generate editable reply suggestions, qualifying questions, and appointment wording based on the customer's message and the selected vehicle's verified inventory details.

AI-generated information may be incomplete, outdated, or incorrect. Dealership employees and authorized users remain responsible for reviewing important information and confirming vehicle availability, pricing, incentives, financing information, trade values, appointment details, and binding customer commitments.

Information processed through AI-enabled features may be shared with approved service providers solely as needed to provide configured functionality, subject to applicable agreements and settings.

Whether service providers may retain or use information to improve their services depends on the provider, contract, configuration, and applicable law. Pro Car Finder must verify and document these practices before making more specific public commitments.

Section 4 — How We Disclose Information

We disclose information only as described in this policy and where permitted, including to:

  • Service providers and contractors
  • Customer-authorized integrations
  • Dealerships, dealer groups, rooftops, and authorized users
  • Payment processors
  • Communications and scheduling providers
  • Professional advisers
  • Legal and safety disclosures
  • Business transactions
  • With customer or user direction

Within an organization, access is based on account role and rooftop. Dealership administrators may manage users and view activity for the rooftops they oversee, and dealerships may control access to their inventory. Because providers and authorized account users may receive information, we do not claim that information is never shared.

Sale or Sharing for Advertising

Pro Car Finder must complete a data-flow and advertising-technology review before stating whether it "sells" or "shares" personal information under any state privacy law.

[LEGAL REVIEW REQUIRED: Confirm whether any analytics, advertising, cookie, or integration activity constitutes a "sale," "sharing," or targeted advertising under applicable law.]

Section 5 — Cookies and Similar Technologies

Cookies or similar technologies may be used to support:

  • Essential site operation
  • Authentication
  • Security
  • Preferences
  • Form protection
  • Performance
  • Analytics

See our Cookie Policy for more detail.

The company must verify the actual cookies, local-storage items, pixels, analytics tools, and consent controls in production before this section is finalized. A cookie-management mechanism is not claimed unless and until implemented.

Section 6 — Data Retention

We retain information for as long as reasonably necessary to provide the Services, maintain accounts, complete transactions, satisfy contractual and legal obligations, resolve disputes, prevent fraud or abuse, protect security, and enforce agreements.

Retention may depend on:

  • Account status
  • Data category
  • Customer configuration
  • Service-provider settings
  • Contractual requirements
  • Legal obligations
  • Dispute or security needs
  • Backup and deletion cycles

[LEGAL AND OPERATIONAL REVIEW REQUIRED: Establish documented retention periods for account data, inventory, forms, diagnostics, billing records, Facebook Lead Assistant replies and outcome records, appointment data, backups, and security logs.]

Section 7 — Security

Pro Car Finder uses administrative, technical, and organizational measures intended to protect information based on the nature of the Services and information involved. No system, transmission, or storage method is completely secure, and Pro Car Finder cannot guarantee absolute security.

We encourage users to:

  • Use strong authentication
  • Restrict authorized access
  • Revoke access in a timely manner when people leave
  • Protect connector keys
  • Avoid password sharing
  • Report suspected unauthorized access

We do not claim encryption, SOC 2, ISO, PCI, penetration testing, backup frequency, or breach-detection capabilities unless documented.

Section 8 — Data Breach and Incident Response

Pro Car Finder will evaluate suspected security incidents and provide legally required notifications where applicable.

[LEGAL AND SECURITY REVIEW REQUIRED: Confirm incident-response procedures, processor notification obligations, breach-assessment process, and Washington RCW 19.255 responsibilities.]

We do not promise a notification deadline unless it accurately matches every applicable law and the company's obligations.

Section 9 — Customer and User Responsibilities

Customers and users are responsible for:

  • Providing lawful and accurate information
  • Obtaining authorization for inventory sources
  • Managing account roles and access
  • Revoking departed employee access
  • Protecting credentials and connector information
  • Providing required customer notices
  • Obtaining required communication consent
  • Honoring opt-out requests
  • Using customer information lawfully
  • Following applicable Marketplace and provider policies
  • Avoiding sensitive information in general forms
  • Configuring human escalation appropriately

Section 10 — Privacy Rights and Requests

Depending on where a person lives and subject to applicable law, they may have rights concerning access, correction, deletion, portability, restriction, objection, consent withdrawal, or appeals.

To make a privacy request:

  • Use our contact form
  • Select "Privacy or Data Request"
  • Or email [PRIVACY EMAIL] once verified

Pro Car Finder may need to verify identity and authority before completing a request. Pro Car Finder may deny or limit a request where permitted by law and will provide information about applicable appeal rights where required.

Do not submit sensitive identity documents through the general contact form.

Authorized Agents

Authorized-agent requests may require proof of authority and identity verification where applicable. Not every listed right applies to every person.

Section 11 — Communication Choices

Some communications are necessary to run an account. In general:

  • Account and service communications may be necessary
  • Marketing email opt-out instructions should be honored
  • SMS opt-out instructions should be honored when SMS is enabled
  • Consent withdrawal does not affect prior lawful processing
  • Some services cannot operate without required communications

To opt out, follow the opt-out instructions provided in the applicable message or contact Pro Car Finder.

Section 12 — Children's Privacy

The Services are intended for automotive professionals and organizations, not children. Pro Car Finder does not knowingly direct the Services to children under 13 or knowingly collect personal information from children under 13 through the Services.

[LEGAL REVIEW REQUIRED: Confirm whether a higher minimum age should apply to accounts or Facebook Lead Assistant communications.]

Pro Car Finder does not claim COPPA compliance as a certification.

Section 13 — Third-Party Services and Links

Facebook, Meta, dealership websites, scheduling tools, communications providers, CRM systems, hosting services, and other third parties may have separate privacy policies. Pro Car Finder is not responsible for independent third-party privacy practices. A link or integration does not imply endorsement. Facebook and Marketplace access is controlled by Meta.

The payment provider is referred to generically as a "payment provider" unless and until a specific provider's payment role is confirmed.

Section 14 — International Data Processing

[LEGAL AND OPERATIONAL REVIEW REQUIRED: Determine whether information is processed outside the user's state or country and whether international-transfer disclosures or safeguards are required.]

Pro Car Finder does not claim that all data remains in the United States unless and until this is verified.

Section 15 — Changes to This Policy

We may update this Privacy Policy to reflect changes in our Services, practices, providers, or legal obligations. The "Last Updated" date will indicate when the policy was revised. Where required, we will provide additional notice.

Section 16 — Contact

[LEGAL BUSINESS NAME]
[MAILING ADDRESS]
Privacy email: [PRIVACY EMAIL]
Support email: [SUPPORT EMAIL]

You can also reach us through our contact form. For privacy requests, choose "Privacy or Data Request."

Do not submit passwords, payment information, identity documents, or other highly sensitive information through the general contact form.